G.R. No. 132136; July 14, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO BAYBADO, accused-appellant.

FACTS

The accused, Rolando Baybado, was charged with the rape of his 15-year-old daughter, Helen. The prosecution evidence established that on the night of May 14, 1994, in their home in Ramon, Isabela, Helen was sleeping beside her sisters when her father transferred beside her, removed her panty and his shorts, and had carnal knowledge with her despite her resistance. He threatened to kill her and her family if she told anyone. Helen later disclosed the rape to her employer, Mrs. Sagun, after her father tried to force her to return home. A medical examination revealed old hymenal lacerations and physical injuries consistent with forced intercourse. Helen testified that this was not an isolated incident, as her father had raped her several times since she was 13 or 14.
The defense presented a denial and alibi. Appellant claimed he was working in Nueva Ecija from 1992 to 1996 and never went home during that period. His wife and another daughter sought to corroborate this, alleging Helen was not at home that night and had filed the case out of anger for being scolded. The Regional Trial Court convicted Baybado of rape and imposed the death penalty, prompting an automatic review by the Supreme Court.

ISSUE

Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of the crime of rape.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The Court found the testimony of the victim, Helen, to be credible, straightforward, and consistent. It held that when the victim’s testimony passes the test of credibility, as it did here, it is sufficient to sustain a conviction for rape. The defense of alibi was properly rejected as it was not physically impossible for the appellant to have been at the crime scene. The Court also noted that the relationship between the accused and the victim, being father and daughter, made the crime qualified rape under the law in effect at the time, warranting the death penalty.
However, applying the ruling in People vs. Echegaray, the Supreme Court reduced the penalty to reclusion perpetua because the qualifying circumstance of relationship was not alleged in the Information with the requisite specificity to justify the death penalty. The Court modified the award of damages, ordering the appellant to pay P50,000 as civil indemnity and an additional P50,000 as moral damages, which are automatically awarded in cases of incestuous rape.